The CBI Index: the due diligence process in the Caribbean

Due diligence varies dramatically across citizenship by investment (CBI) programmes – at one end of the spectrum only basic disclosure requirements are implemented, while at the other extreme there are transparent, thorough, and robust requirements. The quality of a CBI programme rests on its ability to embrace transparent and at times exacting due diligence processes, ongoing monitoring of applicants in case their circumstances change, and absolute clarity around the on-boarding decision-making process.

The Caribbean CBI programmes are generally associated with far-reaching due diligence, and with good reason. Indeed, while their processes may not be completely interchangeable, they all follow the same structure: requirements for extensive disclosure compounded by supporting documentation, comprehensive investigation by independent and professional firms, and information exchange with both regional and international entities involved in crime detection. It is this structure that greatly dissuades individuals who may hope to use the Caribbean’s CBI programmes to circumvent the Common Reporting Standard (CRS) or to conduct other illicit activity.

Growing interest in the topic of immigration, and investor immigration in particular, makes it essential to provide clarity on the steps that are taken to examine individual CBI applicants in certain jurisdictions. It is in S-RM’s purview to provide that clarity with respect to the Caribbean, and to the reports that it provides to the CBI jurisdictions in that region. Each report covers the following areas:  

Address verification – Each applicant is required to detail his or her residential history for at least the last 10 years. Verification of their current residential address is undertaken, either through a site visit or through contacts located in the country who are familiar with the applicant. 

Passport verification – The passports of the applicant and any dependants are verified through an algorithmic check and by the respective issuing authority. 

Police clearance certificates – Applicants and all dependants (above a certain age) are required to provide certificates evidencing no criminal records for each of the jurisdictions they have resided in within the last 10 years. If any further jurisdictions are identified, police clearance certificates are requested by the CBI jurisdiction. The authenticity of these police clearance certificates is verified with the issuing authorities.  

Business profile – Applicants are required to detail all business interests and employment activity for at least the last 10 years. These positions are verified, and further searches are conducted to ensure there are no omissions. Investigations are undertaken to ensure the legitimacy of these entities, both in terms of registration and their business activities. 

Reputation – A thorough analysis is conducted of the applicant’s business reputation through online media and litigation searches, as well as through contact with professional acquaintances, competitors, industry bodies, and a variety of other sources, to certify that the applicant presents no reputational concerns.

AML/CTF/ABC – The applicant is required to provide supporting documents to validate reported financial information, including corporate filings (such as incorporation documents or annual accounts), title deeds for land or property assets, stock portfolios, and bank statements. This information is then analysed for any signs of illicit activity. The applicant’s business interests are also investigated by in-country contacts to ensure there are no allegations of unlawful or otherwise dishonest activity. There is then a detailed assessment of anti-bribery and corruption (ABC), anti-money laundering (AML), counter-terrorism funding (CTF), and related reputational and integrity risks.

Sanctions, wanted lists, and political exposure – The applicant, as well as his or her family, corporate affiliations, and associates are checked through the global wanted lists and sanctions databases to which we subscribe.  The same individuals are run through global compliance databases to ascertain any political exposure. Information from in-country contacts is also used to determine any political links held and the risk they may present.

Due diligence is the most substantial contributing factor to a CBI programme’s capacity to attract the right individuals as citizens. Exhaustive due diligence reports, such as the ones that are undertaken on behalf of Caribbean jurisdictions, should therefore be a staple of all CBI programmes that aspire to success and durability.  

Heyrick Bond Gunning is CEO of S-RM. S-RM is among the panel of due diligence providers that lend their expertise to jurisdictions with CBI programmes. S-RM provides these services for several CBI jurisdictions in the Caribbean and elsewhere around the world. S-RM also provides similar services to the banking and private equity sectors, corporate clients, and other governments. This has allowed S-RM to acquire a broad understanding of the levels of due diligence undertaken across a variety of sectors, and to be able to provide a sound opinion on their strengths.